ML20248L803
| ML20248L803 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/18/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248L792 | List: |
| References | |
| 50-010-98-02, 50-10-98-2, NUDOCS 9803240230 | |
| Download: ML20248L803 (2) | |
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NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-10 Dresden Station License No. DPR-2 During an NRC inspection conducted between December 15,1997, and February 26,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
A. The Dresden Nuclear Power Station, Unit 1, Facility Operating License No. DPR-2,'
Appendix A, Technical Specifications, Section 6.11, requires that, " Procedures for personnel radiation protection shall be . . . adhered to for all operations involving personnel radiation exposure."
- 1. Section G.4.a(4) of Procedure DRP 6020-02, Radiological Air Sampling Program, states, T the initial beta / gamma activity is greater than, or equal to, thirty percent of the station's "most restrictive" DAC limit for beta / gamma, THEN have the air sample immediately counted using a high purity germanium detector."
Contrary to the above, between January 1 and November 21,1997, air samples were not always immediately counted using a high purity germanium detector when the initial beta / gamma activity was determined to be greater than, or equal to, thirty percent of the station's "most restrictive" DAC limit for beta / gamma.
- 2. ' Section F.1.f of DAP 12-25, Radiation Work Permit Program, states, ?lt is the responsibility of personnel performing a job under a RWP to: . . . (4) Follow requirements of RWP."
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Contrary to the above, on October 31,1997, a worker failed to follow RWP 971012 when he dumped contaminated debris located inside a pipe into a bucket of water causing a localized airbome event. The job being performed under RWP 971012 involved cutting out a piece of pipe; the RWP did not provide for decontaminating the pipe in any manner by dumping out intemal contamination.
, 3. Section F.1.c, DAP 12-25, Radiation Work Permit Program, states "It is the responsibility of RP Supervision or designee to: . . . (2) Verify surveys used to generate RWPs reasonably reflect current radiological conditions in the work area."
Contrary to the above, on September 26,1997, a Lead RPS entered the Unit 1 Radweste Vault #1 and failed to verify the radiological conditions reasonably reflected the current radiological conditions in the work area. Specifically, the Lead RPS failed to adequately identify the radiological conditions on the top of the tanks where work was to be performed.
l 4.' Section F.1.d, DAP 12-25, Radiation Work Permit Program, states "It is the responsibility of the RP Technicians (RPTs) to: . . . (2) Perform surveys during the job . . . deemed necessary to verify radiological conditions are as expected."
9903240230 900318 PDR ADOCK 05000010 G PDR
Notice of Violation Contrary to the above, on September 26,1997, a Lead RPS entered the Unit 1 Radwaste Vault #1 and failed to perform surveys during the job necessary to verify radiological conditions were as expected. Specifically, the Lead RPS failed to identify a 150 millirem per hour pipe and a 1 Roentgen per hour hot spot, which would have established that the radiological conditions were aqi as expected.
- 5. Section E.7, DAP 12-04, Control of Access to High Radiation Areas, states
" Personnel requiring access to a HRA/LHRA/VHRA shall receive a briefing from Radiation Protection to include: . . . b. Dose, dose rate, and low dose area information."
Contrary to the above, on September 26,1997, a Pipe Fitter General Foreman failed to be briefed on the dose, dose rate, and low dose areas by Radiation
. Protection before entering the Unit 1 Radwaste Vault #1 which was a High Radiation Area (HRA).
This is a Severity Level IV violation (Supplement IV).
B. The Dresden Nuclear Power Station, Unit 1, Facility Operating License No. DRP-2, Appendix A, Technical Specification 6.12.B, requires that for ". . . areas accessible to personnel with radiation levels greater than 1000 mrem /hr at 30 cm (12 in.) . . . Doors shall be locked to prevent unauthorized entry."
Contrary to the above, on January 14,1998, a door to the Unit 1 Subpile Room was found unlocked. A survey the same day identified a location on the carousel under the Unit i reactor bottom head, which was accessible by climbing up a ladder located within the Subpile Room, with a 1.2 rem / hour oose rate at a distance of one foot.
This is a Severity Level IV violation (Supplement IV).
The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in inspection Report 50-010/98002(DNMS). However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a
- Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region lit, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice of Violation (Notice), within 30 days of the date of the letter transmitting this Notice.
Dated at Lisle, Illinois, this 18th day of March 1998
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